Privacy Policy

Effective date: November 22, 2023

Welcome to Lingo Live, live, one-on-one, personalized, language coaching through video conference anywhere, anytime. As used in this Privacy Policy, the terms “Lingo Live”, “we” and “us” refer to Preply, Inc. If you are accepting the terms of this Privacy Policy as an employee or representative of a company or other legal entity, the terms “you” and “your” will refer to both you, personally, and the entity you represent.

Lingo Live is committed to protecting and respecting your privacy.

This Privacy Policy describes how we collect, use, protect and share information about you that we obtain when you access and use our Platform (defined below), including when you register for an account, participate in training sessions, participate in contests or promotions, or submit questions or feedback. This Privacy Policy also applies to information that we obtain when you communicate or interact with us outside the Platform, including by e-mail, telephone and otherwise.

For purposes of this Privacy Policy, the following defined terms mean:

• “Platform” means, collectively, the Services and the Website.
• “Services” means any and all language coaching services and related services and promotions provided by Lingo Live, including support services.
• “Users” means any and all persons or entities that access or use the Platform. References to “access” and/or “use” of the Platform (and any variations thereof) include the acts of accessing or browsing the Website and accessing or using the Services.
• “Website” means any and all websites owned or operated by Lingo Live (including the website currently located at https://www.lingolive.com), through which access to Lingo’s online marketplace language coaching and/or related features, functionality, tools, and content are available.

Please read this Privacy Policy carefully to understand how we will treat your information before you start to use our Platform or communicate with us outside the Platform.

HOW WE COLLECT INFORMATION

Information You Provide to Us

We collect information that you provide directly to us, including when you search for Services, review search results, register for an account, use the Services, update your e-mail preferences, respond to a survey or provide other feedback about the Platform or contact us with questions or comments about the Platform.

We may also collect information about you when a company or organization authorizes you to manage its account or use our Platform on its behalf.

We will not ask for or request sensitive information such as government identifiers, medical information, or financial information, except (other than in connection to payments). Please do not provide this information to us through e-mails, feedback forms or in any other way unless specifically requested.

Information Generated from Use of the Platform

We also collect certain technical information when you access, browse and use our Platform. This technical information helps us operate and provide our Platform to you, and includes standard information about visits and system capabilities, such as:

• information about the device(s) you use to access our Platform, including MAC address, IP address, browser type, and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, and device identifiers;
• information about your visits to the Platform, including the full URL clickstream to, through, and from the Platform (including date and time);
• information we need and use to facilitate your use of our Platform (including to provide access to third-party websites and services), such as URL requests, destination IP addresses, or device configuration details;
• pages you view, Services you search for, length of time browsing search results, specific search results you select to view; and
• page response times download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), your engagement with certain variable/dynamic elements of a page and methods used to browse away from the page.

We may also collect information using cookies and beacons. (See Cookies and Beacons below for more details.)

Information from Other Sources

We may supplement the technical information we collect from your use of the Platform with information collected by third parties. Such third parties may include service providers, advertising partners, and ad networks that help us understand our Users and provide better service to our Users. On occasion, we may compare or combine data from third-party sources to/with other information we have collected.

We may also collect and compile contact information from other sources in order to contact you if we think you or the company you represent would be interested in our Platform.

Third parties that are unaffiliated with us may also collect information about you, including tracking your browsing history, when you use our Platform. We do not have control over these third-party collection practices.

If you wish to minimize these third-party collections, you can adjust the settings of your browsers or install plug-ins and add-ins. (See Cookies and Beacons below for more details about cookies, beacons, and your choices.)

HOW INFORMATION MAY BE USED

We may use any of the information we collect, including Personally Identifiable Information (defined below), to:

• allow us to operate our Platform, including payment processing, Platform administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
• manage your access to our Platform;
• send you information that enables you to use our Platform;
• contact you directly about activity on your account;
• generate reporting regarding the use of our Services by Users;
• comply with laws and regulations;
• carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection;
• notify you about changes to our Platform;
• fulfill our obligations to our Users in our operation of the Platform, including our provision of Services to them;
• protect the integrity and maintain the security of our Platform, including secured areas of the Platform;
• in any other way that we describe when you provide the information; and
• for any other purpose for which you may provide consent.

In some cases, how we treat and use information will depend on the type of information. Some of the information we collect through your use of our Platform or communications with us, such as your name, address, telephone number, e-mail address, billing information associated with your account, and/or the name of the company or organization on behalf of which you are authorized to use the Platform may personally identify you. We will treat this information as “Personally Identifiable Information”, which shall have the same meaning as “personal data”. We will also treat as Personally Identifiable Information any non-identifiable information that is combined with Personally Identifiable Information.

We may use your information, including Personally Identifiable Information, to:

• respond to your requests, feedback or questions;
• provide you with information about products or services, from us or third parties, that may interest you; and
• send you e-mails about updates, information, or alerts regarding our Platform.

We may use technical information or non-Personally Identifiable Information to:

• evaluate and improve our Platform and present content in the best way for you and for your device(s);
• serve advertisements on or through our Platform; and
• measure or understand the effectiveness of advertising we serve to you and other Users like you, and to deliver relevant advertising to you and other Users like you.

We may also combine technical information or non-Personally Identifiable Information about your use of our Platform with similar information that we obtain from other Users to use in an aggregate or anonymous manner for similar purposes.

We will retain your information for the duration of any active service agreement with you. This and other data may also be corrected or deleted at your request.

HOW INFORMATION MAY BE SHARED

We will not sell or share your Personally Identifiable Information with third parties for the third party’s own direct marketing purposes without your express consent. Please note that if you click on or otherwise interact with an advertisement on our Platform, however, the advertiser may assume that you meet its target criteria, even though we have not shared your Personally Identifiable Information.

We may share any information, including Personally Identifiable Information, with:

• our subsidiaries and affiliates;
• our service providers to the extent reasonably necessary to enable us to operate and provide our Platform to you (e.g., to an e-mail service provider in order to enable us to e-mail you);
• a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personally Identifiable Information held by us about our Users is among the assets transferred;
• a third party with which we must legally share information about you;
• the designated administrator of your account if you have an individual corporate subaccount;
• you, upon your written request;
• the company or organization you represent if that company requests us to do so; and
• other third parties with your explicit consent.

Such disclosures may be for the purpose of:

• complying with any court order, law or legal process, including to respond to any government or regulatory request;
• investigating potential unauthorized access or misuse of our Platform or otherwise enforcing our Terms of Use, Supplemental Terms (as defined below), Platform Rules (as defined below) other agreements;
• protecting the assets rights or property of Lingo Live, including for billing and collection purposes, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• protecting the rights, property, or safety of our Users or others;
• reporting to corporate clients regarding use of the Services by individual subaccounts; and
• for any other purpose disclosed by us when you provide the information.

We do not permit these third parties to use any Personally Identifiable Information we share for any purpose other than to support us and our efforts to operate and provide our Platform to you.

We may share non-Personally Identifiable Information, aggregate or anonymous data:

• with analytics, search engine, or other service providers that help us improve our Platform;
• to report to our affiliates, licensors and service providers, advertising partners and ad networks about the use of various aspects of the Platform;
• with other Users or prospective Users of the Platform; and
• to advertisers and advertising networks to select and serve relevant advertisements.

In the event that we receive a request from a governmental entity to provide it with your Personally Identifiable Information, we will make reasonable attempts to notify you of such request, to the extent reasonably possible and legally permissible.

COOKIES AND BEACONS

We may use cookies, beacons, and similar technologies, now or in the future, to support the functionality of our Platform. This provides a better experience when you visit our Platform and allows us to improve our Services and Platform. Our service providers, advertising partners, and ad networks may use cookies and beacons to collect and share non-Personally Identifiable Information about your activities both on our Platform and on other websites, including, for example, to provide you targeted advertising based upon your interests.

• Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. That cookie then communicates with servers, ours or those of other companies that we authorize to collect data for us, and allows recognition of your personal computer. We associate cookies with Personally Identifiable Information only if you use the automatic recognition capabilities on restricted areas of the Platform, order a Service, use the personalization services available as part of the Platform, or ask us to contact you with additional marketing information. We do not otherwise collect Personally Identifiable Information from browser cookies and we do not associate browser cookies with your Personally Identifiable Information.

To learn more about cookies, you can visit http://www.allaboutcookies.org.

• Our Platform and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, count Users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings, and web pages. You may use the tools in your device to disable these technologies as well.

Managing cookies

We can place cookies on your device by default if they are strictly necessary for the operation of the Platform. For all other types of cookies, we need your consent.

Unless you choose otherwise, we can store and process only those cookies that are necessary for the operation of the Platform. If you don’t want to be tracked by other types of cookies, you can refuse to give your initial consent.

You can check the specific types of cookies in the pop-up window shown during your first visit to the Platform. By clicking “Accept“, you consent to the use of all the cookies and for all purposes mentioned above. You can go to “Cookie Settings” and manually choose the categories of cookies you want to enable or disable. Declining other types of cookies will affect your experience on the Platform since there will be no personalisation during the subsequent uses of the Platform.

You can change or withdraw your consent at any time by contacting us at our  Privacy@LingoLive.com. Also, your web browser allows you to control and limit cookies on the device. Please keep in mind that simply disabling all cookies or all of our cookies in your browser settings may lead to certain sections or features of the Platform not working. Therefore, we recommend using the cookie settings on the Platform instead of disabling all cookies in your web browser.

YOUR CHOICES

You may have the opportunity to receive certain communications from us related to our Platform. If you provide us with your e-mail address in order to receive communications, you can opt out of marketing e-mails at any time by following the instructions at the bottom of our e-mails and adjusting your e-mail preferences. Please note that certain e-mails may be necessary for the operation of our Platform. You will continue to receive these e-mails, if appropriate, even if you unsubscribe from our optional communications.

If you wish to minimize information collected by cookie or beacon, you can adjust the settings of your browsers to notify you when you receive a cookie, which lets you choose whether or not to accept it. You can also set your browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some features and services on our Platform may not work properly if we are not able to recognize and associate you with your account. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

Some browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that Users can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Our Platform does not currently recognize or respond to DNT signals, so DNT settings do not change the way the Platform operates.

Please note that we cannot control how third-party websites or online services you visit through our Platform respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

You may opt out of our direct telemarketing contacts by requesting us to remove you from our direct telemarking list. Please note that opting out from our direct telemarketing contacts does not limit us from contacting you for other purposes, including those contacts that are reasonably necessary to provide you with our Platform.  If you decide to opt out of our direct telemarketing contacts, allow a reasonable time for us to process your request and do not hesitate to contact us at Privacy@LingoLive.com if you encounter any problems with your request. The FTC also maintain a National Do Not Call Registry at www.donotcall.gov/register/reg.aspx. Registering your number with the FTC may also limit our direct marketing contacts to that number.

The accuracy of the information we have about you is very important. Users may update their information at any time by following directions available on the account registration page. Otherwise, to review or correct your Personally Identifiable Information, please contact us at Privacy@LingoLive.com.

SECURING YOUR INFORMATION

The security of your information is important to Lingo Live, and we have established reasonable administrative, technical, and physical safeguards designed to protect Personally Identifiable Information against loss, alteration, unauthorized access, theft, misuse, or disclosure. Unfortunately, no system can guarantee the complete security of your information. As a result, Lingo Live cannot ensure or warrant your information, including your Personally Identifiable Information, is secure from unauthorized third parties. Thus, your use of the Platform and communication with us about them is at your own risk.

You are responsible for protecting your password(s) and for the security of information that you transmit to us over the internet. Corporate clients are responsible for maintaining the security and integrity of both administrator account and individual subaccount login information.

For compliance statements relative to specific laws and regulations that may apply to you, including GDPR or CCPA, please refer to Appendix A.

MINORS

Our Platform is directed to and is intended to be used only by persons who are 18 years of age or older. We do not knowingly collect information from minors under 18. If you are under 18 years of age, you are not permitted to register for an account or otherwise submit any Personally Identifiable Information to us, including your name, address or e-mail address. If we discover that we have collected any Personally Identifiable Information from a minor under the age of 18, we will suspend the associated account and remove that information from our database as soon as possible. By registering for an account or submitting any personally identifiable information to us, you represent and warrant that you are 18 years of age or older.

LINKS TO THIRD-PARTY SITES

Our Platform may contain links to third-party websites and services, including those of our partner networks and advertisers. Please note that these websites and services may have their own privacy policies. This Privacy Policy applies to Lingo Live and our Platform only. We do not accept any responsibility or liability for the policies or practices of any third parties. If you choose to access any websites or services linked to our Platform, please check the applicable policies before you use or submit any personal data to such website or service.

INTERPRETATION

Your use of our Platform may be governed by our Terms of Use located at www.lingolive.com/terms, the supplemental terms that govern certain of the features, functionality, tools, content, and promotions available on or through the Platform (the “Supplemental Terms”), and any and all policies and rules referenced herein or therein, posted on the Platform, or otherwise communicated to our Users (the “Platform Rules”). In the event that the provisions of any such agreement that are specific to a particular Website or App differ from or conflict with the provisions of this Privacy Policy, the terms specific to that Website or App will apply.

CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Policy from time to time to align with changes to our business practices and/or changes to our legal requirements. We will post the updated Privacy Policy on this page (www.lingolive.com/privacy) and will indicate that the updates have been made by changing the effective date first written above. We urge you to check back periodically to check whether there have been updates to our Privacy Policy.

CONTACT

If you have questions, comments or requests relating to this Privacy Policy, please e-mail us at Privacy@LingoLive.com, or write to us at:

Privacy Requests
Preply, Inc.

1309 Beacon Street, Suite 300,

Brookline, MA 02446

Appendix 

A.1 For individuals based in the European Union (EU), European Economic Area (EEA) and Switzerland.

If you are based in one of these jurisdictions, Lingo Live is the controller of your personal data collected in the following instances:

• When you visit our Website at ​​https://www.lingolive.com/
• When we process your personal data for sales and marketing purposes

Lingo Live is a processor of all personal data processed on the Application, on behalf of our clients. We only process the personal data under their direction. Please contact your employer or the organization that granted you access to the Application for details on their privacy practices.

We only process personal data if we have a lawful basis for doing so. The lawful bases applicable to our processing as controller are:

• Consent – We will ask for your express and informed consent before we collect your personal data on this legal basis.
• Contractual basis – We process the personal data as necessary to fulfill our contractual terms with you or our clients.
• Legitimate interest – We process the names, contact details, job titles, companies of our existing and prospective clients for our marketing purposes, including market research and sales leads generation.

You have the following rights under the GDPR:

• Be informed about the collection and use of your personal data
• Access your personal data
• Correct errors in your personal data
• Erase your personal data
• Object to the processing of your personal data.
  • This right is also available to individuals whose personal data is processed by us for direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, we shall stop processing within 30 days of receipt of your request.
• Export your personal data
• Restrict our processing of your personal data for specific reasons, including any of the purposes supported by the legitimate interest legal bases (see the section above).
• Withdraw consent at any time by contacting us

• After we at Lingo Live receive a withdrawal request from you, we will process it in a timely manner, and we will no longer process your personal data unless otherwise set by law.

We process personal data in the United States and share it with our hosting providers located in the United States. We use standard contractual clauses as the data transfer mechanism of transferring EU data to countries subject to data transfer requirements.

You may also lodge a complaint with your local supervisory authority, EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC).

A.2 For individuals based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”).

A.2.1 Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name, mailing address, email address, zip code, telephone number, or other similar identifiers.
• California customer records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address, and department.
• Internet/Network Information, such as your browsing history, log and analytics data, information about the device(s) used to access the Services, and information regarding your interaction with our websites or Services and other usage data.
• Geolocation data, such as information about your location (at country and city level) collected from your IP address.
• Sensory information, the content, audio, and video recordings of conference calls between you and us that we record where permitted by you and/or the law.
• Profession/employment information that you include in your CV, cover letter, and send to us when applying for a position.
• Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry, and any other information you upload to our Application.

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information, or from third parties that share public information about you and as stated above.

See the section above “How Information May Be Used” to understand how we use the personal information collected from California consumers.

A.2.2 Recipients of Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors; (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks.

Please see the “How Information May Be Shared” section of the Privacy Policy above for more information.

A.2.3 California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

• The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or selling the personal information.
• The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
• The Right to Opt-Out of Personal Information sales to third parties now or in the future. However, we do not sell your personal information.

You also have the right to be free of discrimination for exercising these rights.

Please note that if the exercise of these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

A.2.4 How to Exercise Your California Consumer Rights

To exercise your right to know and/or your right to deletion, please submit a request by contacting us at privacy@lingolive.com

We will need to verify your identity before processing your request.

In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you.

We may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems or as permitted by law.

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once a request has been submitted by an authorized agent, we may require additional information (i.e. written authorization from you) to confirm the authorized agent’s authority.

If you are an employee/former employee of a Lingo Live client that uses our Application and Services, please direct your requests and/or questions directly to your employer/former employer.

If you are a third party (auditor, business associate etc.), who was given access to the Lingo Live Application by a Lingo Live client, please direct your requests and/or questions directly to the Lingo Live client that gave you access.